Consultation response
Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response
This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.
Contents
- Executive summary
- Summary of topics
- Topic 1 - Improving customer choice on direct marketing: Consultation Response
- Topic 2 - Strengthening age verification in premises: Consultation Response
- Topic 3 - Game design: Consultation Response
- Topic 4 - Financial vulnerability checks: Consultation Response and Financial risk assessments pilot: Consultation Response
- Topic 5 - Personal Management Licence: Consultation Response
- Topic 6 - Changes to Regulatory Panels: Consultation Response
- Evaluating the impact of relevant changes
- Annex
Summary of new research, data and evidence
We have explained that there was some confusion from some respondents to our consultation and call for evidence exercises, often exacerbated by the fact that those respondents had heard about the proposals via campaigns and trade publications where the details were not fully covered or could be confusing.
For example, some consumers had received the impression that all customer accounts would undergo the checks whereas it was proposed that only a proportion of the highest-spending accounts would have checks. Others had received the impression that the checks proposed were more like a cap on gambling, regardless of the financial circumstances of the customer. The proposals however were not to act as a cap and were designed to take account of the financial circumstances of the customer. Despite concerns, the checks would not affect a customer's credit rating. In September 2023, we made available some information on our website to answer some of the common queries or areas of confusion in a Gambling Commission blog.
Consumer voice research
Alongside the Summer 2023 consultation, we commissioned consumer research to gain greater insights from gambling customers. This consumer voice work has brought in additional perspectives and allowed more in-depth exploration of the issues with a range of consumers. Alongside this response, we publish the results of the consumer research relating to financial risk which we commissioned. The research was conducted by Yonder Consulting.
The research was designed to:
- explore gamblers’ perceptions and whether they support the package of proposals
- understand gamblers’ views on the individual proposals, including perceptions around effectiveness and why the gamblers hold those views
- understand gamblers’ responses to how each proposal could be implemented, such as: net loss thresholds, type of check, data use, validity periods and potential outcomes of the check
- understand any differences between types of gambler, for example: different ages, more active gamblers or those scoring higher on the Problem Gambling Severity Index (PGSI) scale.
Yonder designed a deliberative research approach to enable participants to reflect upon the proposed policies in an environment free from media influence where information could be explained and explored. The qualitative phase consisted of 4 focus groups and 4 in-depth interviews (a total of 28 participants) with a cross-section of online gamblers and was conducted in August 2023. The reflections from the qualitative sessions were used to inform a quantitative survey phase. Data was collected from 1,000 online gamblers in November 2023.
The findings: Overall response to the proposals
Yonder found high levels of overall support for the proposals in both the qualitative and quantitative stages, and a recognition that the proposals are necessary to protect online gamblers from harm. Despite some variation between types of gamblers, the majority across all groups still support the proposals being implemented.
Key findings include:
- 78 percent agree that the package of proposals is necessary to protect people from gambling harm (6 percent disagree) and 74 percent would support the package of proposals being implemented (7 percent disagree)
- 61 percent disagree that the package of proposals is unclear in its aim or purpose of protecting people from gambling harm (16 percent agree) and 46 percent disagree the package is disproportionate (21 percent agree)
- respondents who scored higher on the PGSI and reported more active online gambling accounts were less supportive of the package of proposals.
The findings: Financial vulnerability checks
For financial vulnerability checks, Yonder found broad support for the current proposals. 56 percent felt that the proposed threshold of £125 in 30 days is the right amount, and 52 percent felt that the £500 in 365-day proposed threshold is also the right amount.
Of those that disagreed, respondents were more likely to feel the consultation proposed thresholds are too low (30 percent for £125 in 30 days and 31 percent for £500 in 365 days), a view that was also expressed in the qualitative stage. It was felt that the proposed threshold would impact most gamblers and when presented with the full proposal and frictionless nature of the check, some felt it would be better as a blanket check across all customers.
A majority (68 percent) were favourable towards the use of publicly available data to check if a customer was financially vulnerable (11 percent were not favourable towards this). However, there is also concern over whether this type of data would miss people who are financially vulnerable but do not have these public records.
The findings: Financial risk assessments
For financial risk assessments, Yonder again found broad support for the current proposals. 51 percent felt the thresholds of £1000 in 24-hours and £2000 in 90-days are the right amounts (35 percent and 30 percent respectively felt they are too high, whilst 6 percent and 10 percent respectively felt they were too low). Whilst both thresholds were also broadly supported in the qualitative phase, gamblers struggled to relate to the 90-day time period with their typical week or calendar month view of gambling.
The proposed lower thresholds for young adults received support amongst survey respondents (74 percent agreed, 15 percent disagreed), even amongst 18 to 24 year olds. Despite mild objections in the qualitative stage regarding the reasoning behind the lower thresholds there was widespread support for higher protection.
Survey respondents were favourable towards the use of credit reference agency data (65 percent favourable, 14 percent unfavourable). This was reflected in the qualitative stage, although support is dependent on assurance that the check would have no impact on an individual’s credit record.
Updated YouGov data on discretionary income
The Gambling Commission 2020 to 2021 consultation and call for evidence on remote customer interaction included information about average discretionary income, from YouGov. This indicated the average levels of discretionary income per calendar month at different age groups. In each age group, there are individuals who have very limited discretionary income.
In this response, we provide updated information about average discretionary income from obtained from YouGov.
There remains a significant proportion of the population falling within the lowest 3 categories of discretionary income compared to the 2020 figures, but the proportions are reduced compared to the 2020 figures. The proportions of the general adult population that had an average monthly discretionary income of Nothing (8 percent in 2024 compared to 9 percent in 2020), less than £125 (21 percent in 2024 compared to 25 percent in 2020) or in the £125 to £249 range (17 percent in 2024 compared to 20 percent in 2020).
Personal monthly discretionary income by age group1
| Personal monthly discretionary income (February 2024) | All ages (percentage) | 18 to 24 years old (percentage) | 25 to 34 years old (percentage) | 35 to 44 years old (percentage) | 45 to 54 years old (percentage) | 55 years old and above (percentage) |
|---|---|---|---|---|---|---|
| Nothing | 8% | 6% | 6% | 9% | 10% | 7% |
| Less than £125 | 21% | 21% | 15% | 21% | 22% | 22% |
| £125 to £249 | 17% | 16% | 15% | 17% | 17% | 17% |
| £250 to £449 | 15% | 14% | 18% | 17% | 15% | 14% |
| £500 to £749 | 9% | 7% | 13% | 9% | 8% | 8% |
| £750 to £999 | 5% | 4% | 7% | 4% | 5% | 4% |
| £1,000 to £1,249 | 4% | 3% | 6% | 5% | 4% | 4% |
| £1,250 to £1,499 | 2% | 2% | 3% | 2% | 2% | 1% |
| £1,500 to £1,749 | 1% | 2% | 2% | 2% | 1% | 1% |
| £1,750 to £1,999 | 1% | 1% | 1% | 1% | 1% | 1% |
| £2,000 and above | 3% | 2% | 3% | 3% | 2% | 3% |
| Do not know | 6% | 11% | 5% | 4% | 5% | 6% |
| Prefer not to say | 10% | 11% | 7% | 7% | 8% | 12% |
Open banking data modelling
Open banking protocols enable individuals’ financial data to be shared between banks and third-party service providers.
In 2023 the Commission purchased a sample of open banking data from YouGov Finance. This dataset includes the details of banking transactions from 4,000 individuals in Great Britain, each of whom have given their consent for their data to be used for research. It comprises over 12 million individual transactions, of which 253,916 are non-lottery gambling transactions, by 2,034 unique gamblers. At least one year of transactions is available for each gambler, with an average of 966 days and a standard deviation of 222 days. The data spans the period up to August 2023.
Alongside this response, we publish a technical report on the data-modelling exercise.
This publication sets out the results of an analysis of open banking data. A data modelling approach was taken to consider the proportion of individuals whose rate of gambling spend exceeded certain thresholds. The report considered the overlap between the groups of individuals exceeding the different thresholds, as well as whether the thresholds are still reached when considering spend at each gambling operator separately compared to overall gambling spend.
The Open Banking modelling necessarily applied different definitions of spend that those proposed in the consultation. However, based on those definitions, we note that almost every unique individual exceeding a £500 threshold also exceeded a £125 threshold or a £150 threshold. Only 1 percent of individuals in the sample (which deliberately over-represented gamblers and was not nationally representative) would be captured by the £500 annual threshold, whilst not also exceeding the £125 (monthly) threshold or 1.6 percent at a £150 threshold.
When considering the 2 potential risk assessment thresholds for single operator net spend, we saw that similar numbers of individuals exceeded each, with 93 and 95 unique individuals for the £1,000 and £2,000 thresholds respectively. There is a large overlap in the sets of unique individuals identified by each. However, for each of these thresholds between a fifth and a quarter of individuals identified did not exceed the other threshold. This results in a notably higher number of unique individuals exceeding at least one risk assessment threshold than either threshold alone.
Details on our next steps is set out in:
Our position: Light-touch financial vulnerability checks
Our position: Next steps for a pilot of enhanced financial risk assessments
References
1 Unweighted Numbers: All (110,203), 18 to 24 years old (5,515), 24 to 34 years old (14,949), 35 to 44 years old (19,152), 45 to 54 years old (19,211), 55 years old and above (51,376).
Base: Respondents aged 18 years old and above, living in Great Britain (data weighted by age, ethnicity, gender, education level, social grade, past vote and political attention). Source: YouGov Profiles
Last updated: 1 May 2024
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